Prevention of Sexual Harassment (POSH) Policy

At Sanam Designs Wallah – Manki Space, we are committed to a workplace where every person feels safe, respected and able to do their best work. This policy explains what sexual harassment is, what we do to prevent it, and exactly how anyone can raise a concern and have it dealt with fairly. It is framed in line with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("the POSH Act") and its Rules. Effective date: 17 June 2026.

1. 01. Our Commitment and Who This Covers

   Manki Space does not tolerate sexual harassment in any form. We are committed to providing a working environment that is free from harassment, intimidation and discrimination, and to dealing with every complaint seriously, fairly and confidentially.

   This policy applies to everyone connected with our workplace, regardless of seniority, role or how they are engaged with us:

   • All employees — full-time, part-time, on probation, on contract, trainees and interns.
   • Consultants, freelancers, vendors, contractors and their staff who work at or with our premises.
   • Job applicants and visitors who interact with our people in a work context.

   The POSH Act provides protection to any woman, whether or not she is employed by us, who alleges sexual harassment at our workplace. While the Act is framed to protect women, Manki Space applies the spirit of this policy to everyone, and any person who experiences such behaviour can raise it through the channels described here.

   "Workplace" is read broadly. It includes our office and premises, any location an employee visits for work (including a client site or a vendor's office), transport provided or arranged for work, work-related events and travel, and online and remote settings such as email, WhatsApp, video calls, chat tools and social media used for work.

2. 02. What Counts as Sexual Harassment

   Sexual harassment is any unwelcome behaviour of a sexual nature, whether physical, verbal, written, visual or digital. "Unwelcome" is judged from the point of view of the person experiencing it — intent does not excuse the conduct. It includes any one or more of the following:

   • Unwelcome physical contact, advances or touching.
   • A demand or request for sexual favours.
   • Sexually coloured remarks, jokes, comments about a person's body or appearance, or repeated unwanted attention.
   • Showing or sending pornography or sexually explicit images, messages, memes or links.
   • Any other unwelcome physical, verbal or non-verbal conduct of a sexual nature — including staring, gestures, stalking, or persistent unwanted messages on phone or social media.

   It is also sexual harassment when any of the following are linked, openly or by implication, to a person's employment:

   • A promise of preferential treatment (a raise, promotion, project, or favour) in return for a sexual favour.
   • A threat of detrimental treatment (a poor rating, demotion, or loss of work) for refusing.
   • A threat about a person's present or future employment status.
   • Interfering with someone's work or creating an intimidating, hostile or offensive working environment.
   • Humiliating treatment likely to affect a person's health or safety.

   These behaviours are unacceptable whether they happen in person, in writing, or through any digital channel, and whether between colleagues, from a senior to a junior, or involving clients, vendors or visitors.

3. 03. The Internal Committee (IC)

   We have constituted an Internal Committee (IC) — the body responsible for receiving and inquiring into complaints of sexual harassment — as required by the POSH Act. The IC is composed in line with the Act:

   • A Presiding Officer who is a woman employed at a senior level.
   • At least two members from among employees, preferably committed to the cause of women or with relevant experience.
   • One external member from an NGO or association committed to the cause of women, or a person familiar with issues relating to sexual harassment.
   • At least half of the total members of the IC are women.

   IC members are appointed for a term of up to three years. Where a complaint involves an IC member, that member steps aside from the matter to avoid any conflict of interest.

   The current names and contact details of the IC members are displayed at our workplace and shared with all employees. If you are unsure who to contact, write to mayank@themanki.com and you will be directed to the IC.

4. 04. How to File a Complaint

   If you have experienced sexual harassment, you can make a written complaint to the Internal Committee. We encourage you to come forward — raising a concern is always the right thing to do, and we will support you through the process.

   • Submit your complaint in writing to any IC member, or to the Presiding Officer. If you need help putting it in writing, an IC member will assist you.
   • A complaint should ordinarily be made within 3 months of the incident, or within 3 months of the last incident in a series. The IC may extend this period if there were valid reasons that prevented an earlier complaint.
   • Where the person is unable to make the complaint themselves — for reasons of physical or mental incapacity, or death — a relative, friend, co-worker or other authorised person may file it on their behalf, as permitted under the Rules.

   Your complaint should describe what happened as clearly as you can — what was said or done, when and where, who was involved, and the names of any witnesses. You may attach any supporting material such as messages, emails or screenshots.

   Before the inquiry begins, and if you request it, the IC may take steps to help resolve the matter through conciliation — but only if you ask for it, and never by way of a monetary settlement as a condition. Conciliation is voluntary, and you can choose a formal inquiry instead at any time.

5. 05. The Inquiry Process and Timelines

   The IC inquires into every complaint fairly, giving both the complainant and the respondent a proper opportunity to be heard. The process follows the principles of natural justice.

   • On receiving a complaint, the IC provides a copy to the respondent, who is given an opportunity to respond, ordinarily within 10 working days.
   • Both parties may present their account, lead evidence and name witnesses. Neither party is allowed to bring a lawyer to represent them in the proceedings.
   • Where the complainant or respondent is an employee, our service rules apply; where the respondent is not an employee (for example a client or vendor), the IC proceeds under the POSH Act.
   • During the inquiry the IC may, at the complainant's request, recommend interim relief — such as transferring either party, granting leave to the complainant of up to three months, or restraining the respondent from reporting on the complainant's work.

   Timelines we follow:

   • The inquiry is completed within 90 days of receiving the complaint.
   • The IC submits its inquiry report to the employer within 10 days of completing the inquiry, and a copy is given to both parties.
   • Where the IC finds the allegation proved, it recommends action against the respondent — which may include a warning, withholding of increment or promotion, transfer, or termination, in line with our service rules and the Act. It may also recommend deduction from the respondent's salary as compensation to the complainant.
   • The employer acts on the IC's recommendations within 60 days of receiving the report.

   Either party may appeal against the findings or recommendations to the appropriate court or tribunal within 90 days, as provided under the Act.

6. 06. Confidentiality

   We treat every complaint with strict confidentiality. The identity and addresses of the complainant, the respondent, the witnesses, and any information about the inquiry, the recommendations and the action taken are kept confidential.

   This information is not published, communicated or made known to the public, press or media in any manner. It is shared only with those directly involved in handling the matter, on a need-to-know basis.

   Breaching this confidentiality is itself a disciplinary matter. Any person who discloses protected information in contravention of the Act may face action, including the penalty specified under the POSH Act and Rules.

   Information about the justice secured to a complainant may be disseminated only without revealing identities or any particulars that could lead to identification.

7. 07. Protection Against Retaliation and Handling of False Complaints

   No one will face any adverse consequence for making a complaint in good faith, for being a witness, or for taking part in an inquiry. Retaliation of any kind — including victimisation, exclusion, an unfair appraisal, withdrawal of work, or pressure to withdraw a complaint — is itself a violation of this policy and will be treated as misconduct.

   If you believe you are being retaliated against in connection with a POSH matter, report it immediately to the IC or to mayank@themanki.com, and it will be acted on.

   At the same time, this process must not be misused. If the IC concludes, after inquiry, that a complaint was made maliciously or knowingly false, or that forged or misleading evidence was produced, it may recommend action against the person who did so.

   • A complaint that simply cannot be proved is NOT a false complaint. The inability to substantiate a complaint or to provide adequate proof does not, by itself, attract any action against the complainant.
   • Action for a malicious complaint is taken only where malice or knowing falsehood is established through inquiry, and only after giving that person a fair hearing.

8. 08. Awareness, Training and Records

   Prevention is as important as redressal. We take active steps to build an aware and respectful workplace:

   • This policy is shared with every new joiner and is available to all team members at any time.
   • We display the consequences of sexual harassment and the names and contact details of the IC at conspicuous places in the workplace.
   • We conduct periodic orientation and awareness sessions for all employees, and capacity-building sessions for IC members.
   • We sensitise our teams to handle complaints with empathy, fairness and confidentiality.

   The IC prepares an annual report of complaints received and disposed of, which the employer files with the District Officer as required by the Act, and includes the number of cases in our records in line with applicable law.

   We review this policy from time to time to keep it accurate and effective, and to reflect any changes in the law.

9. 09. Contact and Escalation

   If you have experienced or witnessed sexual harassment, have a question about this policy, or are unsure who to approach, please reach out. You will be treated with respect and your concern will be handled confidentially.

   • Internal Committee: contact any IC member or the Presiding Officer directly. Names and contact details are displayed at the workplace.
   • Founder / Management escalation: Mayank Agarwal — mayank@themanki.com, +91 70022 08642.
   • External recourse: if a complaint involves the employer, or you wish to escalate beyond the IC, you may approach the Local Committee constituted by the District Officer under the POSH Act, and you retain the right to take the matter to the appropriate court or tribunal.

   Raising a concern early helps us act quickly and protect everyone involved. We will stand by anyone who comes forward in good faith.